Guidelines
1. Act responsibly towards society and strive to raise
the corporate value of the Citizen Group.
(1) We shall observe the local laws and ordinances of countries and regions
where business operations are performed, and make an effort to always act
in an ethical manner, so that the products and services provided can beaccepted by the society as items with true value.
( 2) We shall maintain an awareness regarding boosting the corporate value of
the Group through “manufacturing of products that are loved and trustedby citizens,” and shall place importance on having an attitude of mutual
understanding and recognition.

(3) We shall aim for the ongoing development of the Group, recognize thevarious risks and challenges that exist in society, and take action to develop
the Group by operating in a responsible and thoughtful manner within thecontext of the societies in which we engage.

Citizen Group Code of Conduct

2. Create and promote products and services that demonstrate
our commitment to safety, quality, and the environment.
● Provision of products and services(1) We shall provide products and services while accurately grasping the needsof society, pursuing safety and quality, and giving consideration to theenvironment.
(2) In order to guarantee quality, we shall establish and put into practicestandards and procedures that must be followed in each stage fromdevelopment to manufacturing, sales, and after-sales service.
(3) If there is a defect in a product or service, we shall respond in a swift andappropriate manner, and make an effort to prevent reoccurrence.

● Implementation of sincere service for customers and ethical marketing(4) In order to boost customer satisfaction, we shall develop contact points forresponding to feedback and inquiries from customers, and shall work toenhance service follow-up systems.
(5) We shall clearly and accurately provide information about products, service
content and handling displays, etc., so that customers can make rational choices.
(6) We shall not use expressions that lead to any type of discrimination related toracial, religious, cultural, or other types of social groups.
(7) We shall not use slanderous or defamatory expressions with regard tocompetitors.
(8) When using the company name or group brand logo for products we shall observein-house regulations related to such use.

Guidelines

3. Engage in business practices that are fair, transparent,
open to competition, and responsible.
● Fair, transparent, and free competition(1) We shall only engage in competition on the premise that such competition isfair and free, and shall not pursue profits based on unjust means.
(2) We shall not abuse business partners by taking advantage of dominantbargaining positions, including but not limited to imposing unjust conditions
such as excessive cost reduction measure, denying the receipt of goods,
returning goods, and delaying payments.
(3) We shall continuously review commercial practices with a view to economic
rationality, consumer interests, transparency, and fairness.
(4) We shall thoroughly understand that bribery is considered a criminal offense
in many countries, and shall observe the related laws and ordinances ofcountries in which business activities are carried out.
(5) We shall not offer or pay bribes to anyone, regardless of whether they are apublic official, private company, individual, or corporation.
(6) The receipt of business gifts and business entertainment shall be within thescope of the common social practices, and we shall observe in-house
regulations related to the prevention of bribery, gifts and entertainment.
(7) When an offer of gifts or entertainment has been received, we shall consider
this objectively and carefully, and if feeling unsure, shall seek the opinion of
the department chief or relevant company’s supervisor of legal affairs.

● Handling of government agencies, etc.
(8) We shall maintain clean and sound relationships with government agencies,etc., and shall not provide illegal political donations or facilitation payments.
Furthermore, employees shall not give donations to government agencies, etc.
conditioned on the receipt of business opportunities or other favors.
(9) We shall seek the advice of the relevant company’s supervisor of legal affairs
when interacting with government agencies, etc.
(10) We shall provide cooperation regarding the relevant inquiries andinvestigations of government agencies, etc. in a sincere and prompt manner.

Citizen Group Code of Conduct● Import and export management(11) Laws and regulations related to import and export are not only complicated,but also frequently revised, hence when carrying out import and exporttransactions, we shall contact a department specializing in import and exporttransactions and other relevant persons.
(12) In particular, when importing or exporting products, services, or technologies,
we shall observe the relevant laws and regulations, and shall accurately carryout the prescribed procedures related to the necessary authorization,application, and reports.

● Prohibition of contact with antisocial forces(13) We shall not interact with antisocial forces. We shall respond to antisocial
forces with a firm attitude, and shall handle antisocial forces in cooperation
with the police and regional community.
(14) We shall never provide donations or sponsorship funds or purchase materials,etc. if this could potentially lead to unjust revenues for antisocial forces.

● Prevention of money laundering(15) We shall understand that money laundering is a criminal activity.
(16) We shall be cautious of business partners that are passive regarding
providing the necessary information for transactions, that provide insufficient
information, and of business partners that provide incorrect information.
(17) We shall request the provision of sufficient information in response torequests for suspicious money transfers, in which they are asked to sendmoney to an irrelevant third country or are asked to return money via anelectronic money transfer after a payment has been made in cash.

● Responsible and sustainable procurement(18) In regard to purchasing transactions with suppliers, we shall take into
consideration not only economic rationality, but also laws and regulations,compliance with social norms, respect for human rights, occupational healthand safety, and commitments to environmental preservation.
(19) We shall put into practice responsible and sustainable procurement andavoid supporting conflicts through procurement activities.

Guidelines

4. Respect human rights and diversity, and provide a safeand pleasant working environment.
● Respect for human rights(1) We shall place importance on respecting basic human rights no matter where
they are.
(2) We shall never accept child labor, forced labor, or human trafficking.
(3) We shall mutually respect privacy.
(4) We shall treat the personal information of customers, business partners, andemployees as secrets and handle this with the utmost care.
(5) We shall never accept any type of discrimination (discrimination based on
gender, sexual orientation, age, physical or mental disabilities, nationality,race, skin color, religion, marriage history, etc.).
(6) We shall respect basic rights in labor related to freedom of association andcollective bargaining.

● Creating pleasant working environments(7) We shall make an effort to communicate in an honest and open manner inorder to build mutual trust.
(8) We shall take an interest in improving our own workplace environment andshall share ideas in this regard.
(9) With a view to creating human resource development programs and life plans,
we shall understand that personality traits, unique characteristics, anddiversity are to be respected, and shall strive to improve our own qualities.
(10) We shall aim to create workplaces that are free from harassment andpestering, etc.
(11) We shall take care to avoid actions that hurt others, make others
uncomfortable, humiliate others, and actions that could be interpreted as anact of intimidation.

Citizen Group Code of Conduct● Ensuring health and safety at workplaces(12) In order to ensure the safety of workplace environments and prevent
unforeseen accidents and disasters, we shall always pay attention to safety
during work and shall thoroughly inspect equipment, and perform
maintenance in an appropriate manner.
(13) We shall promote the creation of workplaces that give consideration tophysical and mental health, are hygienic, and promote health.
(14) We shall develop awareness regarding a work-life balance in which there isharmony between work and childrearing, nursing care, and so on.
(15) We shall not work while under the influence of alcohol or narcotics.

Guidelines

5. Recognize the importance of environmental conservation,and take voluntary and proactive measures.
(1) In each stage of business activities from the planning of products to researchand development, design, procurement, production, sales, usage, disposal, andrecycling, we shall make an effort to reduce the Group’s environmental impact
and lessen environmental risks.
(2) We shall strive to develop products, services, and technologies that take into
consideration environmental protection, including energy and resource
consideration, and shall thereby proactively provide society withenvironmentally-friendly products and services.
(3) We shall suitably manage waste from business activities, and promote reuse
and recycling.
(4) We shall observe laws and regulations related to chemical substances, andshall manage chemical substances based on methods that lessen their impact
on health and the environment.

Citizen Group Code of Conduct

6. Manage and protect company assets
in an appropriate manner.
● Thoroughly maintaining use for business purposes(1) We shall not use company assets (tangible or intangible assets) for personal
purposes. Furthermore, we shall not mix company assets that have been
loaned for business operations with personal assets.
(2) We shall only use company assets for legitimate business purposes, and shallnot use company equipment or systems to access, download, or transfer, etc.
information that contains inappropriate content.

● Management of intellectual property and confidential information(3) We shall respect intellectual property rights such as patent rights, utility
model rights, design rights, and trademark rights, acquire intellectual
property rights in accordance with prescribed procedures, and make an effort
to avoid infringing the intellectual property rights of others.
(4) We shall not leak work-related secrets that have come to be known in thecourse of implementing professional duties, during employment at thecompany or after leaving the company.
(5) We shall make an effort to carry out thorough and appropriate information
management regarding the information of customers and business partners
and confidential business information that is an important management asset.
(6) We shall understand that the loss or leakage of information due tocarelessness can lead to enormous damages and the reduction of trust, andshall therefore take care regarding the handling of various types ofinformation.

Guidelines
7. Abstain from actions that would harmthe company’s long-lasting values.
● Conflicts of interest related to employment(1) We shall avoid giving priority to personal interests over company interestsand engaging in tasks and activities that are unrelated to company operations
during work hours, and performing any activity that could be interpreted as
being similar to this.
(2) We shall not engage in activities that could be considered competition withthe Group.
(3) We shall not employ or engage in business with the executives of customer
companies or business partners without carrying out the prescribed approval
procedures for doing so.
(4) We shall avoid offering employment to the family members of the executives
and employees of the Group at customer companies and business partners,
and giving preferential treatment to such persons.
(5) If being in a position with influence over hiring decisions, we shall avoid
placing our own family members and relatives under our supervision.
(6) We shall avoid having romantic relationship with persons of direct reportingrelationship, which could influence evaluation and remuneration.

● Prohibition of insider trading(7) We shall not use information that we have come to know in the course of workfor personal gains.
(8) If possessing insider information, we shall not buy or sell shares of Citizen
Watch Co., Ltd. Furthermore, if having obtained insider information
regarding another company through work, we shall not buy or sell shares ofthat company.
(9) We shall not disclose insider information inside or outside of the company, andshall thus make an effort to avoid violating insider trading regulations, etc.

● Disclosing company information and responding to shareholders
and investors(10) We shall accurately disclose company information, product information, andshareholder and investor information, etc. via the department with jjurisdiction using a suitable medium.

Citizen Group Code of Conduct(11)We shall accurately record accounting information in accordance with accounting
standards and the relevant laws and regulations. Furthermore, members of theGroup shall promptly and accurately disclose through appropriate channels
important information that could influence financial information and stock prices toall shareholders and investors.
(12) We shall place importance on relations with shareholders and investors, and shallpromote suitable Investor Relations activities. Furthermore, members of the Groupshall make an effort to take opinions received through dialogue with shareholders andinvestors seriously, and to reflect these in business management.
(13) We shall sincerely and promptly respond to accounting audits and tax investigations,and shall provide cooperation for the creation and disclosure of correct financialstatements. If the company is to undergo an investigation by a public institution dueto a suspected violation of laws and ordinances, we shall cooperate in a sincere andprompt manner with a view to clarifying the real situation.
(14) We shall not engage in any activities that give favors to specific shareholders. We
shall not engage in derivative transactions (speculative trading) that carry the risk ofsignificantly reducing the asset value of the company. In the case of carrying out
derivative transactions, this shall be done in accordance with in-house regulations.

● Distinction between public and private statements(15) When expressing personal opinions, including on the internet and in social media,
we shall not use formats that include the company name or group brand logo, or an email address that contains the company domain name.
(16) We shall understand that any secrets or privacy can not be secured on the internet.
In particular, we shall understand that in social media posting, personal statements
could be interpreted as official announcements of the Group.
(17) When announcing company information to outside of the company and when
expressing opinions from a standpoint of affiliation with the company, we shall do soin an appropriate manner through the department in charge.

● Personal political activities(18) When engaging in independent political activities, we shall clarify that ourstandpoint is not related to the company.
(19) If carrying out election support and lobbying activities, we shall do so from an
independent standpoint outside of company facilities and outside of work hours.

Guidelines

8. Strive to contribute to regional communities
in which we operate.
(1) We shall contribute to the development of regional communities throughbusiness activities based on consultations with regions and mutual trust.
(2) We shall make an effort to foster a flexible and creative corporate culture
through further deepening relations with regional communities byestablishing friendships with local residents and cooperating with regional
vitalization efforts.
(3) We shall carry out social contribution activities in collaboration with NPOs,
NGOs, volunteer organizations, regional communities, and so on.

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